Bonilla v. Santa Clara County Superior Court

Background

Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The court identified the matters by these case numbers: 24-cv-2153-PJH, 24-cv-2180-PJH, 24-cv-2181-PJH, 24-cv-2182-PJH, 24-cv-2239-PJH, 24-cv-2241-PJH, 24-cv-2242-PJH, 24-cv-2243-PJH, 24-cv-2254-PJH, 24-cv-2261-PJH, 24-cv-2308-PJH, 24-cv-2437-PJH, 24-cv-2438-PJH, and 24-cv-2439-PJH.

The complaints presented nearly identical claims against various state courts and agencies. Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts. The court also noted that he had a pending federal petition in another matter with appointed counsel and was represented by counsel in state proceedings.

Filing-fee status

To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from that status unless he was in imminent danger of serious physical injury when he filed his complaints. The court relied on prior rulings concerning Bonilla and found that the allegations did not show imminent danger at the time of filing. The court therefore held that he could not proceed under that status.

Other grounds for dismissal

The court further stated that, even if a filing-fee application were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying civil-rights claims. It also described Bonilla as having an extensive history of filing similar frivolous cases.

Ruling

Judge Phyllis Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.